Republic of Liberia Liberia Land Authorityemansion.gov.lr/doc/LLA ESMF .pdf · Republic of Liberia...

Environmental & Social Management Framework (ESMF)

LIBERIA LAND ADMINISTRATION PROJECT

(LLAP)

June 2017

Republic of Liberia

Liberia Land Authority

Liberia Land Authority: Liberia Land Administration Project - Environmental and Social Management Framework

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LIST OF ABREVIATIONS

BP Bank Procedure

CNDRA Center for National Documents and Records Agency

DLSC

EA

Department of Lands, Survey and Cartography

Environmental Assessment

EIA Environmental Impact Assessment

EIS Environmental Impact Statement

EMP Environmental Management Plan

EMS Environmental Management Systems

EPA Environmental Protection Agency

ESIA Environmental and Social Impact Assessment

ESMP Environmental and Social Management Plan

FDA

GIS

GOL

LC

Forestry Development Authority

Geographic Information System

Government of Liberia

Land Commission

LLA

LLAP

Liberia Land Authority

Liberia Land Administration Project

MIA Ministry of Internal Affairs

MME Ministry of Mines and Energy

NGOs Non-Governmental Organizations

OP Operational Policy


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TABLE OF CONTENTS

EXECUTIVE SUMMARY ............................................................................................................................................ 4

1.0 INTRODUCTION ...................................................................................................................................... 7

1.1 Background ............................................................................................................................................................................. 7

1.2 Project Components ............................................................................................................................................................ 7

1.3 Objectives of the ESMF ....................................................................................................................................................... 9

2.0 POLICY, LEGAL AND ADMINISTRATIVE FRAMEWORK ...........................................................10

2.1 Liberia Environmental Policy Requirements ........................................................................................................ 10

2.2 The Environmental Protection Agency Act ............................................................................................................ 10

2.3 EPA Regulations and Procedures ............................................................................................................................... 10

2.4 National Land Rights Policy .......................................................................................................................................... 12

2.5 The World Bank Requirements ................................................................................................................................... 12

2.6 Administrative Framework and Institutional Roles and Responsibilities ................................................ 13

3.0 DESCRIPTION OF THE PROJECT ENVIRONMENT ......................................................................16

3.1 Project Area ........................................................................................................................................................................ 16

3.2 County Location and Size ............................................................................................................................................... 16

4.0 POTENTIAL ENVIRONMENTAL AND SOCIAL RISKS AND IMPACTS .....................................17

4.1 Potential impacts on the physical environment ................................................................................................... 17

4.2 Positive Environmental Impacts ................................................................................................................................. 17

4.3 Potential impacts on the social environment ........................................................................................................ 18

5.0 PROPOSED FRAMEWORK ENVIRONMENTAL MITIGATION AND MONITORING PLAN .18

5.1 Monitoring Plan ................................................................................................................................................................. 19

5.2 Framework ESMP Implementation and Monitoring Arrangements ............................................................ 19

6.0 INSTITUTIONAL CAPACITY FOR SAFEGUARDS IMPLEMENTATION AND TRAINING ....20

7.0 SAFEGUARDS IMPLEMENTATION BUDGET .................................................................................20

8.0 GRIEVANCE REDRESS MECHANISM ...............................................................................................21

9.0 STAKEHOLDER CONSULTATION .....................................................................................................22

10.0 DISCLOSURE ...........................................................................................................................................23

11.0 ANNEXES ..................................................................................................................................................24

Annex 1 Screening Checklist ................................................................................................................................................. 24

Annex 2 Stakeholder Meeting in Caldwell ...................................................................................................................... 26

Annex 3 Stakeholder Meeting in Brewerville ................................................................................................................ 29

Annex 4 Stakeholder Meeting in Paynesville ................................................................................................................. 31

Annex 5 Stakeholder Meeting with Civil Society Groups .......................................................................................... 33

Annex 6 Stakeholder Meeting with Environmental Protection Agency ............................................................. 34


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EXECUTIVE SUMMARY Introduction

This report presents an Environmental and Social Management Frame (ESMF) for the proposed Liberia Land

Administration Project (LLAP) in support of one of the critical constraints to Liberia’s sustained and inclusive

growth - land administration, including land ownership and land tenure security. To address this constraint

and many other constraints in the land sector, several laws and policies have been enacted, while others,

including the Land Right Act are pending enactment.

A proposed Land Rights Act to legally recognize customary land ownership has been drafted and submitted to

the National Legislature since 2014 for passage. It is currently under consideration at the legislature after a

series of nationwide consultations with relevant stakeholders. Up to date, land rights remain poorly defined,

with many rural lands having overlapping and unresolved ownership, in particular with regards to Tribal

Lands Certificates (TLC) and mining, forestry and agriculture concessions. The situation is even more complex

given the fact that the implementation mandate for land administration and management is spread across a

number of agencies, including: Department of Lands, Survey and Cartography (DLSC) of the former Ministry

of Lands, Mines and Energy (now Ministry of Mines and Energy); Center for National Documents and Records

Agency (CNDRA); Probate courts; Ministry of Public Works; Liberia Revenue Authority; Liberian Institute for

Statistics and Geo-information Services (LISGIS); Ministry of Internal Affairs; Municipalities and local

authorities; and other sectorial ministries and agencies that are responsible for their own regulatory and land

use planning.

To address some of the challenges outlined, the Government of Liberia created a national Land Commission

in 2009 to explore and analyze Liberia’s land tenure issues and propose policy and legal reform. The term of

the Land Commission expired in January 2016 when a new body, the Liberia Land Authority (LLA) was created

to replace it. With the passing of the LLA Act by the Legislature in October 2016, the LLA has the legal

mandate for land administration in Liberia. Even though the LLA has been legally established, its transition

phase and operationalization have not yet started. To support the ongoing reforms in the land sector, the

Liberia Land Administration Project (LLAP) is being developed with support from the World Bank.

Project Development Objective

The Project Development Objective is to strengthen the institutional capacity of the Liberia Land Authority

and establish a land administration system.

Project Components

The Land Administration Project has four components. Summary of the proposed components are listed

below:

Component 1: Support to the Liberia Land Authority: Support the operationalization of the LLA and its core

responsibilities, including but not limited to: land laws/regulations and administrative procedures; business

systems, plans and processes as well as a strategic investment strategy for financial sustainability; capacity

building; communication and awareness raising; and acquisition of office equipment, furniture, supplies and

vehicles necessary for conducting the work of the Project.

Component 2: Support for inventory and development of policy for tribal land certificates: Project support

will focus on conducting an inventory and analysis of tribal land certificates in five counties (yet to be

determined). The documentation activities wil include a thorough communication strategy to ensure that

community members understand that this is purely a documentation exercise without any legal implications.

A central database will be developed to capture existing inventories and inventories established under this

Project.


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Component 3: Development of a Land Administration System: Project support will focus on developing

strategies and options for a land information and administration system for Liberia, which may include

studies of legal arrangements (such as title versus deeds registries), technology for gathering and recording

land rights, and land information platforms for managing and utilizing land records and rights. Support will

also focus on the establishment of a geodetic network as a common referencing system for all surveys,

mapping, engineering, and construction projects.

Component 4: Project Coordination, Monitoring and Evaluation: The project is expected to be implemented

through a Project Implementation Unit (PIU) under the LLA. As such, this component will be used to support

fiduciary and monitoring and evaluation functions and other operational costs required for project

implementation. This component will also include the baseline, social assessment, mid-term and end-of-term

evaluations.

Project Area Description

The Project scope is national and field work will be limited to Component 2. The inventory of tribal land

certificates under Component 2 will involve data gathering in a limited number of not yet determined

counties. A detailed description of the biophysical environment is not included in the ESMF since all the

activities, except minor renovation works on existing infrastructures (LLA offices), will be very low impact

activities with little or no impact on the environment and people. A social assessment will be undertaken in

year one of project implementation as part of the baseline study which will provide more information on the

socio-economic environment, which is very important in the context of this project.

Legal and Institutional Framework

The preparation of this ESMF takes into consideration applicable policies and legislation in the context of

Liberian law and policies as well as the World Bank safeguards policies. The ESMF is informed mainly by the

Environment Protection and Management Law of Liberia, the Environmental Impact Assessment (EIA)

guidelines, and the relevant safeguards policies of the World Bank.

Several institutions will be involved in the implementation of this project and the ESMF. The Liberia Land

Authority will be the principal agency implementing this project. Other institutions that will be involved in

ensuring safeguards implementation and compliance is the Environmental Protection Agency (EPA). The

World Bank through its project supervision missions will monitor safeguards implementation as required.

World Bank Policies and Project Category

Two World Bank policies have been triggered by this project including OP 4.01 (Environment Assessment)

and OP 4.36 (Forests Policy). No major investments that could have potential impacts on the environment

and social risks are expected to be undertaken. While some minor renovation works are expected under

Component 1, Component 2 will undertake policy support work with potential social implications that are

unclear at the moment. The Project has been categorized as B and hence partial environmental assessment is

required.

Potential Impacts

The project components were analyzed in order to assess the potential impacts the project may have on the

environment and people. Two of the four components of the components may generate some level of

impacts. Minor renovation works on LLA facilities could be undertaken under Component 1. This will mainly

involve masonry, carpentry and electrical works with minimal impacts on the environment and people.

Potential impacts and risks including waste generation and occupational health and safety related issues will

need to be addressed. Some level of construction wastes, including some potentially toxic and hazardous

wastes such empty paint and creosote cans, will need to be disposed of properly. Though the renovation

works are expected to be light, workers may still encounter minor and, sometimes, major occupational


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health and safety issues daily that need to be addressed to avoid workplace accidents. The social implication

of some activities under Component 2 is not fully understood at this stage. Outcome of the social assessment

that will be undertaken during the baseline study to inform the ESMF on the social impacts, if any.

Proposed Mitigation Measures

This ESMF outlines processes that will be followed during project implementation to mitigate potential

impacts on the environment and people. The ESMF contains an Environmental and Social Mitigation Plan

(ESMP) as well as a screening checklist, which will be key in managing potential project impacts and

evaluating impacts of individual project activities, respectively. Concerning the two main impacts identified,

proper disposal of wastes generated, especially those containing potentially harmful substances, is key, while

contractors will be required to ensure safe and healthy work environment through proper arrangements and

management in order to safeguard workers’ and public safety and any other occupational health and safety

issues that may arise.

Grievance Redress Mechanism (GRM)

The project proposes to make use of existing institutional structures under the LLA to facilitate the receipt and resolution of complaints during project implementation. This would be achieved through a 3-Tier arrangement.

Tier 1: Complaints will be recorded by dedicated officers at (i) the Local offices of the LLA and (ii) the LLA headquarters in Monrovia

Tier 2: Unresolved grievances may be referred to the Office of the Executive Director of the LLA. A team will be constituted including legal and land experts for resolution

Tier 3: All unresolved grievances would be referred to the Board of Commissioners of the LLA for final determination. It is expected that an appropriate resolution would be made to the satisfaction of the complainant.

Where a complainant remains unsatisfied with the response or procedures of the project GRM recourse to the state courts becomes the final avenue.

Stakeholder consultation

Public consultations were held in selected towns including Caldwell, Brewerville and Paynesville where the

local community members and their traditional leaders participated. Similar consultations took place in

Monrovia for targeted institutions such as the EPA, CSOs and decentralized government ministries and

agencies of the LLA during the preparation of the ESMF. In addition, joint stakeholder consultations were

held in some places for the ESMF and on the Land Rights Bill.

Summary of Public Consultations

Local community/ targeted institution

Date No of participants

1 Caldwell 18

2 Brewerville 20

3 Paynesville 23

4 Taditional Leaders/ legal profession/CSOs

35

5 EPA 12

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1.0 INTRODUCTION 1.1 Background

Land and land related issues pose major constraints to Liberia’s sustained and inclusive growth.

Livelihoods of Liberians, particularly the rural poor, are impacted by or dependent upon land and land

based resources. Lingering issues of unequal access to and ownership of land, which have persisted over

Liberia’s history, have contributed to economic and social inequities which in turn have exacerbated

tensions and led to conflicts. The absence of a clear land rights policy has resulted in competing and

often overlapping land rights.

The situation is even more complex in areas affected by mining, forestry and agriculture concessions.

The Government of Liberia (GOL), recognizing the critical importance of land as an essential resource for

effecting economic growth and revitalization, has embarked on an ambitious land tenure reform

program through the establishment, by an Act of Legislature, of a Land Commission in 2009. The

Commission has subsequently developed a national Land Rights Policy, which for the first time in

Liberia’s history clearly identifies and defines four distinct land rights categories (Public, Private,

Government and Customary/Community). The Commission has subsequently drafted a Land Rights Act,

which is currently before the Legislature for passage into law.

Implementation of the Land Rights Act, when enacted into law, will require the provision of land

administration services to ensure that land is properly identified, associated rights established and

recorded, and systems for managing this information put in place. Existing land administration systems

are inadequate and inefficient and although significant improvements have been initiated during recent

times, the current state of Liberia’s deed registry is unsatisfactory and the provision of land information

services is inadequate. To implement the Land Rights Act, a Liberia Land Administration Project (LLAP)

was developed with support from the World Bank. As envisaged the LLAP will support the institutional

capacity building of the Liberia Land Authority (LLA) and establish a land administration system.

The Liberia Land Authority (LLA) was established with the passing of the LLA Act by the Legislature in

October 2016. The LLA has the legal mandate for land administration in Liberia. The LLA will subsume

the Department of Lands, Surveys and Cartography (DLSC) under the Ministry of Mines and Energy, the

Deeds Registry currently within the Center for National Documents and Records Agency (CNDRA), and

relevant functions from the Ministry of Internal Affairs (e.g. County Land Commissioners). The LLA’s

main activities will focus on a) land policy and planning, b) provision of land survey, registration and

mapping services, c) provision of land valuation services, d) creation of a national Land Information

System, e) alternative land dispute resolution services, f) coordination of access to government and

public land for investment and conservation projects, g) promotion of land use planning and zoning by

local governments, and h) demarcation and titling of the customary land rights of local communities.

1.2 Project Components

Although not all the components will require an Environmental and Social Impact Assessment, they are

summarized below to provide an overview:

Component 1: Support to the Liberia Land Authority

With the passing of the LLA Act by the Legislature in October 2016, the LLA has the legal mandate for

land administration in Liberia. Even though the LLA has been legally established, its transition phase

and operationalization have not started yet. The LLA will need support in key areas to become

operational. Activities will focus on support to the operationalization of the LLA and its core


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responsibilities, including but not limited to: land laws/regulations and administrative procedures;

business systems, plans and processes as well as a strategic investment strategy for financial

sustainability; capacity building; communication and awareness raising; establishment of decentralized

offices of the LLA located across the country that could be renovated and furnished; and office

equipment, furniture, supplies and vehicles necessary for conducting the work of the Project. Work on

legislation will be informed by the planned social assessment to be undertaken in year one of project

implementation and other consultations and will be sensitive to vulnerable or disenfranchised groups.

Component 2: Support for inventory and development of policy for tribal land certificates

Tribal land certificates refer to a legal, procedural document issued by the County Land Commissioner

under the 1973 Public Land Sale Law, certifying the consent of tribal authorities (chiefs, elders, etc.) to

sell customary land through the Public Land Sale Program. While the Government introduced tribal

certificates initially as a tool to enable customary land to be sold, many local Chiefs issued tribal

certificates to community members under the assumption that the certificate guarantees their tenure

security. The different understanding of the Government and the communities about the rights the

certificates provide, has led to conflicts and undermined investment. Large, but unknown numbers of

tribal certificates exist, but the total extent of areas covered by them is unclear. Inventories were

completed in four counties and piloted in three other counties with support from USAID and SIDA. A full

inventory process is necessary to provide a broader basis for the analysis of the extent and

understanding of tribal certificates, the amount of customary land transferred to public land, and the

overlap of the certificates with other forms of land rights. The data will also inform the development of a

tribal land certificate policy, which will be necessary to establish a land administration system. The

inventory of tribal certificates will be preceded by the social assessment, which will identify and inform

on the associated social risks and impacts.

Component 3: Development of a land administration system

Liberia does not have a system to record and manage land rights information. Further support and

analysis to establish a land administration system is required, specifically with regard to customary land

rights. The activities under this component will support assessments and pilots in key areas of the 2015

Land Administration Policy: survey and mapping; recording of land rights; valuation of land; land use

planning; and management of government and public land. Project support will focus on necessary steps

to establish a geodetic network. This component will also support assessments and pilots to determine

best methods for collecting, recording and managing land rights information. This support will develop

and begin implementing a road map including strategies and options for a land administration system

leading to the establishment of a land administration system in Liberia (deed or title based). Activities to

support land valuation could include the development of standards and procedures for the valuation of

land and property. Further, a coordinated institutional framework for the management of both

Government and Public Land could be supported under this component.

Component 4: Project Coordination, Monitoring and Evaluation

The Project is expected to be implemented through a Project Implementation Unit (PIU) under the LLA.

There is need to ensure that the LLA has adequate capacity to provide effective project management,

adequate safeguards implementation support, fiduciary support (financial management and

procurement), monitoring and evaluation of project activities and the establishment of a solid M&E

framework. As such, this component will be used to support operational costs required for project

implementation within the framework of the LLA. The project will also undertake the baseline study,


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social assessment and the mid-term and end-of-project evaluations in order to assess performance and

document important lessons to inform the design of future operations.

1.3 Objectives of the ESMF

The objective of the ESMF is to screen for potential environmental and social risks and impacts

associated with the subprojects/activities; propose the mechanism and procedure for identifying and

implementing measures that will prevent, minimize or help manage negative and compensate

environmental and social impacts, monitor and report on the status of implementation of the plans and

measures for better environmental and social outcome for any eligible subproject. The ESMF focuses

specifically on:

Policy, legal and administration framework;

Description of the Project Environment;

Assessment of potential environmental and social risks and Impacts (positive and negative) and

Mitigation Measures;

Public Consultation, Stakeholder participation and disclosure; and

Environmental and Social Management Plan.


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2.0 POLICY, LEGAL AND ADMINISTRATIVE FRAMEWORK

This section reviews the national policies, regulations, procedures and legal provisions relating to the

environment, land ownership or acquisition, resettlement and compensations. The reviews have been

made against the World Bank safeguards policies’ requirements. The relevant policies, legal and

administrative frameworks considered are:

Liberia Environmental Policy;

The Environmental Protection Agency Act;

Environmental Protection Agency Regulations and Procedures;

National Land Rights Policy;

The World Bank’s policies and guidance on Environmental Assessment (OP 4.01) and Forests

(OP4.36)

2.1 Liberia Environmental Policy Requirements

The environmental policy of Liberia hinges strongly on ‘prevention’ as the most effective tool for

environmental protection. The policy aims at a sound management of resources and environment, and

the reconciliation between economic planning and environmental resources utilization for sustainable

national development. It also seeks, among others, to institute an environmental quality control and

sustainable development programs by requiring prior environmental assessment of all developments,

and to take appropriate measures to protect critical eco-systems, including the flora and fauna

(contained) against harmful effects, nuisance or destructive practices. The adoption of this led to the

enactment of the EPA Act of 2003; and subsequently the passing of the Liberia EIA Procedures into the

EA Regulations.

2.2 The Environmental Protection Agency Act

The Environmental Protection Agency (EPA) Act grants the Agency enforcement and standards-setting

powers, and the power to ensure compliance with the Liberia environmental assessment

requirements/procedures. Additionally, the Agency is required to create environmental awareness and

build environmental capacity as it relates to all sectors, among others. The Agency is also vested with the

power to determine what constitutes an adverse effect on the environment or an activity posing a

serious threat to the environment or public health, to require environmental assessments (EA),

environmental management plans (EMP) etc. of an undertaking, to regulate and serve an enforcement

notice for any offending or non-complying undertaking. The Agency is required to conduct monitoring to

verify compliance with given approval/permit conditions, required environmental standard and

mitigation commitments.

2.3 EPA Regulations and Procedures

The EPA Regulations combine both assessment and environmental management systems. The

regulations prohibit commencing an undertaking/activity without prior registration and Environmental

Permit (EP). Undertakings are grouped into schedules for ease of screening and registration and for the

EP. The schedules include undertakings requiring registration and EP (Schedule 1), EIA mandatory

undertakings (Schedule 2), as well as Schedule 5-relevant undertakings (located in Environmentally

Sensitive Areas).


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The Regulations also define the relevant stages and actions, including: registration, screening,

Preliminary Environmental Assessment (PEA), Scoping and Terms of Reference (TOR), Environmental

Impact Assessment (EIA), review of EA reports, public notices and hearings, environmental permitting

and certification, fees payment, EMP, suspension/revocation of permit, complaints/appeals etc. As

required, a project brief was prepared and submitted to the EPA for screening. Given the proposed

project activities and level of potential impacts, a full impact study was required but further study was

required to develop an Environmental Review Report. The EIA guideline is presented below in Figure 1.

FIGURE 1 EIA GUIDELINES


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2.4 National Land Rights Policy

A Land Rights Policy was endorsed by Government in 2013. The Policy provides recommendations for

land rights in Liberia, based on four land rights categories: Public Land, Government Land, Customary

Land and Private Land. The Policy recommends the full legal recognition of customary land rights by

protecting customary and private land equally. The Land Rights Policy of Liberia aims at promoting the

judicious use of the nation’s land and all its natural resources by all sections of the Liberian society in

support of various socio-economic activities undertaken in accordance with sustainable resource

management principles and in maintaining viable ecosystems. Key policy provisions include facilitating

equitable access to land, guaranteeing security of tenure and protection of land rights, ensuring

sustainable land use and enhancing land capability and land conservation.

In 2014 the LLC (now the LLA) drafted a Land Rights Act, which is currently pending approval of the

Senate. The Land Rights Act draft is based on the recommendations from the Land Rights Policy and

reflects the four categories of land ownership as outlined above. The Land Rights Act draft seeks to

ensure that customary land is given protection equal to private land for all Liberians. Further, the Land

Rights Act draft prescribes the means by which land may be acquired, used, transferred and otherwise

managed.

Possibly, the first formal legal recognition of community land in Liberia was the issuance of a deed in

1876 for conditional fee simple ownership. Fee simple ownership was subject to three conditions: (1)

demonstrating “civilized” customs, (2) cultivating a certain amount of coffee trees, and (3) building on

the land. The law that authorized the deed gave each male member of the tribe one town lot and thirty

acres of farmland. These individual holdings likely remained subject to customary law, and thus within

a larger community land tenure system. Individual or family- based holdings, even when a community

has a deed for its land, are not uncommon as the customary tenure system persists, which allows for

such holdings. This land administration setting makes Liberia likely the first African state or colony to

formally recognize community land.

2.5 The World Bank Requirements

The World Bank’s safeguard policies are designed to help ensure that programs proposed for financing

are environmentally and socially sustainable, and thus improve decision-making. The Bank’s

Operational Policies (OP) are meant to ensure that operations of the Bank do not lead to adverse

impacts or cause any harm.

Two of the Bank’s Safeguard Policies, are have been triggered under the project: These are:

Environmental Assessment (OP 4.01) and Forests (OP4.36)

Environmental Assessment (OP 4.01)

OP 4.01 (Environmental Assessment) has been triggered due to the fact that some of the project

activities could involve minor renovation works to targeted LLA’s offices around the country. The exact

number of offices to be renovated and the scale of renovation works are not yet established at this point.

However, one of the key findings of the Institutional Audit of the key Liberian Land Governance

Institutions conducted by USAID in 2006 indicates that the Land Commission’s (now LLA) offices in

various county administrative offices around the country are inadequate and would need upgrading to

improve the work environment for the employees and to be able to hire additional staff to assist the

planned County Land Boards in conducting tasks such as land dispute resolution. These renovations and

upgrading works will be covered under Component 1. The potential impacts of these activities are

expected to be minor, and short-term. The project support to the LLA will also include work on

legislation. It is not known at this stage the type of legislation and the impacts it may have on access to


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and use of forest resources. Given that the renovation works and support to legislation are not defined

at this stage, this ESMF is prepared now, while specific Environmental Impact Assessment (EIA) will be

prepared at the time of implementation when these activities are defined and their locations known. OP

4.01 requires among others that screening for potential impacts is carried out early, in order to

determine the level of EPA to assess and mitigate potential adverse impacts. The Bank’s project

screening criteria group projects into three categories:

Category A – A proposed project is classified as Category A if it is likely to have adverse impacts

that are significant and irreversible (based on type, location, sensitivity, and scale of the project

and the nature and magnitude of its environmental impacts).

Category B –A proposed project is classified as category B if the potential impacts are typically

site specific, reversible in nature, less adverse than Category A projects, and for which mitigation

measures can be designed more readily.

Category C – A proposed project is classified as a category C if there are minimal or no adverse

impacts.

Of the Bank’s project screening criteria, this Project is considered a Category B project, Partial

Assessment. Under the national EIA regulation, this project did not require full EIA after screening of

project brief. The proponent was requested to do further study and develop an Environmental Review

Report for approval by the EPA. This is almost the equivalent of partial assessment under OP 4.01.

Forests (OP 4.36)

OP 4.36 (Forests) has been triggered because Component 1 of the project will provide support to the

LLA, and this will include, among other activities, “work on legislation”. It is not clear at this stage what

“work on legislation” will entail, hence its impacts on access to and use of forest resources cannot be

established. OP.4.36 has been triggered as a matter of precaution since work on legislation could have

potential impacts on the health and quality of forest, affect the rights and welfare of people dependent

on forests, or bring about changes in the management, protection and utilization of forest resources. No

standalone safeguards instrument is required at this stage to address the triggering of this OP apart

from the ESMF. However, during year one of project implementation a social assessment would be

conducted to identify any potential social risks and impacts that may be associated with this type of land

operation. Additionally, when “work on legislation” is defined at a later stage, and depending on its

potential impacts, the necessary activity- and specific social and environmental mitigation plans will

have to be completed, prior to implementing those activities of the project triggering this OP. These

plans could include livelihood restoration plan, stakeholders’ engagement plan, etc.

Bank’s Policy on Disclosure (BP 17.50)

The Bank’s policy on disclosure requires that all the people residing in the given areas of a project have

the right to be informed of the proposed development project. Prior to project appraisal therefore, the

summary of the study of the development action along with other relevant information should be

disclosed nationally and in the project area as well as through the Bank website. The ESMF will be

disclosed in a language and areas accessible to potential affected people and all stakeholders, including

the project website, and then by the Bank’s on its website upon authorization of the government. The

ESMF will be distributed to relevant ministries, offices of the LLA, and other relevant public locations.

2.6 Administrative Framework and Institutional Roles and Responsibilities


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2.6.1 The Liberia Land Authority (LLA) The Liberia Land Authority (LLA) was established with the passing of the LLA Act1 by the Legislature in October 2016. The LLA has the legal mandate for land administration in Liberia. The LLA will subsume the Department of Lands, Surveys and Cartography (DLSC) under the Ministry of Mines and Energy, the Deeds Registry currently within the Center for National Documents and Records Agency (CNDRA), and relevant functions from the Ministry of Internal Affairs (e.g. County Land Commissioners). The LLA’s main activities will focus on a) land policy and planning, b) provision of land survey, registration and mapping services, c) provision of land valuation services, d) creation of a national Land Information System, e) alternative land dispute resolution services, f) coordination of access to government and public land for investment and conservation projects, g) promotion of land use planning and zoning by local governments, and h) demarcation and titling of the customary land rights of local communities.

2.6.2 Ministry of Mines and Energy (MME) The Vision and Mission of the MME (former Ministry of Lands, Mines and Energy) is to ensure the

sustainable management and utilization of Liberia’s lands and mineral resources for socio-economic

growth and development.

The Ministry's activities and implementation of the current reforms are in pursuance of its set aims and

objectives. These are:

Develop and manage sustainable lands and mineral resources;

To facilitate equitable access, benefit sharing from and security to land and mineral resources;

Promote public awareness and local communities’ participation in sustainable mineral and land

use management and utilization;

To review, update, harmonise and consolidate existing legislation and policies affecting land and

mineral resources;

To promote and facilitate effective private sector participation in land service delivery and

mineral resource management and utilization;

Develop and maintain effective institutional capacity and capability at the national, regional,

district and community levels for land and mineral service delivery; and

Develop and research into problems of mineral resources and land use.

2.6.1 Environmental Protection Agency The Environmental Protection Agency (EPA) Act grants the Agency enforcement and standards-setting

powers, and the power to ensure compliance with the Liberia environmental assessment

requirements/procedures. Additionally, the Agency is required to create environmental awareness and

build environmental capacity as it relates to all sectors, among others. The Agency is also vested with the

power to determine what constitutes an adverse effect on the environment or an activity posing a

serious threat to the environment or public health, to require environmental assessments (EA),

environmental management plans (EMP) etc. of an undertaking, to regulate and serve an enforcement

notice for any offending or non-complying undertaking. The Agency is required to conduct monitoring to

verify compliance with given approval/permit conditions, required environmental standard and

mitigation commitments.

1 GoL (2016): An Act to Amend Title 12, Executive Law of the Liberian Codes of Law Revised and to Add

Thereto a New Chapter Creating the Liberia Land Authority.


15 | P a g e

2.6.2 Ministry of Internal Affairs

The Ministry of Internal Affairs, the Nation’s oldest and largest institution, has seen significant reforms

since its establishment in 1864. The changes were manifested in all key areas, including its Mandate,

Nomenclature and Structure.

In the first few decades of the young Republic, the territorial influence of government could be extended

and felt only a few hundred kilometres in-land from the coast. Interaction with the rural masses was

very limited. Therefore, the institution’s responsibility was, to Administer Local Governance which

basically involved Collection of Taxes, Maintenance of Peace and Tranquillity, and Seeking the Welfare of

the People. The Ministry of Internal Affairs plays a major role in public consultation, especially on land

related issues.

2.6.3 Forestry Development Authority

The Forestry Development Authority is a state corporation established by an Act of the Legislature in

1976 with the mandate to sustainably manage and conserve all forest resources for the benefit of

present and future generation. This mandate was strengthened through the National Resource Law of

1979. The 2006 Forestry Reform Law of Liberia is the current legal instrument that guides the

management of forest resources in Liberia.


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3.0 DESCRIPTION OF THE PROJECT ENVIRONMENT

3.1 Project Area

The Project scope is national and field work will be limited to Component 2. The inventory of tribal land

certificates under Component 2 will involve data gathering in a limited number of counties to be

determined during project implementation. A detailed description of the biophysical environment has

not been undertaken in the development of the ESMF. This information is not relevant for assessing the

risk and impacts the project may generate since all the activities, except minor renovation works on

existing infrastructures (LLA offices), will be very low impact activities with little or no impact on the

environment and people. Besides, most of the activities envisaged under this project are institutional

strengthening activities with little or physical investments. A social assessment will be undertaken in

year one of project implementation as part of the baseline study which will provide more information on

the socio-economic environment, which is very important in the context of this project.

3.2 County Location and Size Liberia lies on the southwest corner of the West Coast of Africa within the Mano river basin. It borders

with the Atlantic Ocean in the south, Sierra Leone in the west, Guinea in the north and Cote d’Ivoire in the

east. Its geographical coordinates are: latitudes 4o18’ and 8o30' north and longitudes of 7o30' and 11o30'

west. It covers an area of about km2 111,370, of which km2 96,160 are land and 1,505 inland water. It lies

within the upper Guinean Forest region and prior to the impact of man was almost entirely covered by

tropical moist forest.

Liberia has a population of 3.9 million (2010 EST) and Monrovia, its capital city is the country’s largest city.

There are 15 administrative counties in Liberia. The Project area covers the whole country (See Figure 2).

Figure 2: Map of Liberia


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4.0 POTENTIAL ENVIRONMENTAL AND SOCIAL RISKS AND IMPACTS

4.1 Potential impacts on the physical environment

The project is not expected to have any significant impact on the environment and people. Component 1

of the LLAP which is geared toward institutional reforms may require some renovation and setting up of

infra-structures as its Headquarter and the establishment of local offices. It could require the renovation

of existing buildings. The renovation of buildings to house the LLA could require some civil works to be

selected for the Headquarters and Local Offices. Renovation works could take place in areas that are

already urbanized. They are unlikely to have significant negative impacts. Likely environmental

concerns may be related to slight local modification in air quality, insignificant rise in ambient noise

levels and vibration and management of waste during renovation work. Summary of potential

environmental and impacts are discussed below.

Flora and Fauna: The removal of the vegetative cover and cutting of trees (non-economic trees) are not

expected under this project. So no impacts are expected with regard to vegetation cover and fauna,

hence specific mitigation measures are not required.

Soil Erosion: No civil work is anticipated under this project. Renovation works will be carried out on

existing structures and in existing facilities. Soil erosion is not anticipated. No mitigation measures are

required.

Air Quality: Minor renovation works envisaged under this project will not lead to any noticeable change

in air quality.

Solid Wastes: Renovation works would generally generate construction wastes that need to be managed.

The renovation works will entail mainly masonry, carpentry and electrical works required for upgrading

and improving existing facilities. The level of construction wastes that may be generated as result of

these activities are expected to be minimal but will still require proper disposal. Those of major concern

will include but are not limited to empty paint and thinner cans, and chemicals used in wood processing

to prevent termites such as creosote. Proper handling and disposal of these cans, some of which contain

toxic substances, will need to be adhered to.

Occupational Health and Safety: Though renovation works are expected to be light, workers may still

encounter minor and, sometimes, major occupational health and safety issues that need to be addressed

to avoid workplace accidents. The exact facility renovation and upgrading activities are not defined at

this stage, but these activities would normally involve, for instance, working at height in case of roof

repair work; issues related to electricity and welding safety; exposure to hazardous substances such as

paints, thinners, creosote during painting and wood processing; and the risk of trip and fall as result of

poor housekeeping in the workplace. The contractor will need to ensure safe and healthy work

environment through proper arrangements and management. Some generic mitigation measures to be

instituted are provided in the Environmental Mitigation and Monitoring Plan (see Chapter 5).

4.2 Positive Environmental Impacts

The institutional support to the LLA provided under this project will in the long term have positive

environmental impacts, such as:

Improved efficiency in resource use, administration and cost effectiveness of the land sector

agencies


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Proper demarcations of forest reserves, conservation areas, prevention of encroachment and

reduced land degradation and loss of biodiversity

4.3 Potential impacts on the social environment

Component 2 of the project will support a full inventory process that is necessary to provide a broader

basis for the analysis of the extent and understanding of tribal certificates, and to eventually establish a

land administration system. This component will also include support to policies related to tribal land

certificates. Activities to be supported under this component, though not yet finalized, may have some

associated social impacts and risks which are not fully understood at this stage. A social assessment

aimed at understanding the social risks and impacts the project may generate will be undertaken during

the baseline study, prior to undertaking associated activities under Component 2.

While the potential negative risks and impacts of these interventions are not fully established at this

stage, there are potential positive impacts the project hopes to achieve in the long term, including but

not limited to improved land tenure security, increased land-related investment, improved efficiency of

land resource use, and increased transparency in the land sector.

5.0 PROPOSED FRAMEWORK ENVIRONMENTAL MITIGATION AND MONITORING PLAN

The project components as well as the proposed activities are expected to be low impact as activities are

not expected to have any impact of significance to the biophysical environment (land, air, water, flora

and fauna). The scale of social impact the project may generate is not fully understood at this stage. The

results of the social assessment will inform the ESMF regarding the social risks and impacts, if any, and

the necessary plans to be developed.

TABLE 1 FRAMEWORK ENVIRONMENTAL AND SOCIAL MITIGATION PLAN

ACTIVITY PARAMETER MITIGATION MEASURES CHECKLIST

General Conditions

Notification, Worker

and Public Safety

(a) Contractor will be responsible to ensure that work environment is safe and healthy

(b) The LLA will be responsible to ensure that this ESMF is included in contractor’s contract and implementation enforced

(c) The public has been notified of the works through appropriate notification in the media and/or at publicly accessible sites (including the site of the works)

(d) All legally required permits have been acquired for rehabilitation (e) The Contractor formally agrees that all work will be carried out in a safe and

disciplined manner designed to minimize impacts on neighboring residents and environment.

(f) Workers’ PPE will be supplied with the required PPE for their work (g) Appropriate signposting of the sites will inform workers of key rules and

regulations to follow. (h) Contractors will take appropriate measures to ensure that those who are

not involved with renovation works are kept off site.

General renovation and upgrading Activities

Air Quality, noise,

water quality, erosion

Except where activity and site screening results show that there might be negative impacts, no mitigation measures are so far required. Renovation works are expected to be of very low impact on these media even in the absence any mitigation measure.

Wastes

(a) Waste collection and disposal pathways and sites will be identified for all major waste types expected from all activities.

(b) Solid waste will be collected and disposed properly in accordance with Environmental Legislation of RA


19 | P a g e

ACTIVITY PARAMETER MITIGATION MEASURES CHECKLIST

(c) The records of waste disposal will be maintained as proof for proper management as designed.

(d) Whenever feasible the contractor will reuse and recycle appropriate and viable materials

(e) Toxic and hazardous wastes including empty paint cans will dispose of in general community waste disposal sites

(f) Open burning of wastes will not be allowed (g) Dumping of wastes in water courses and in other environmentally

sensitive areas such as swamps/wetlands will not be allowed

5.1 Monitoring Plan

The objective of the monitoring plan is to establish appropriate criteria to verify the predicted impacts

of the project, and to ensure that any unforeseen impacts are detected and the mitigation adjusted

where needed at an early stage. The plan will ensure that mitigating measures are implemented. Specific

objectives of the monitoring plan are to:

Check the effectiveness of recommended mitigation measures;

Demonstrate that sub-project activities are carried out in accordance with the prescribed

mitigation measures and existing regulatory procedures; and

Provide early warning signals whenever an impact indicator approaches a critical level.

Oversight for the environmental and social management process of the sub-projects will be

assured by the supervisory consultants in collaboration with the LLA.

The project’s safeguards consultants will prepare a long term monitoring strategy that will encompass

clear and definitive parameters to be monitored. The monitoring plan will take into consideration the

scope of the environmental and social sensitivity and the financial and technical means available for

monitoring. The plan will identify and describe the indicators to be used, the frequency of monitoring

and the standard (baseline) against which the indicators will be measured for compliance with the

ESMP.

The verifiable indicators will include (1) completed checklists, (2) environmental briefs submitted to the

EPA, (3) action plans prepared and implemented, (4) EPA permits, and (5) Number and quality of

monitoring reports.

5.2 Framework ESMP Implementation and Monitoring Arrangements

The Land Authority

The Liberia Land Authority was established by an Act in October 2016 replacing the Land Commission of

Liberia established in 2009. The primary mandate of the Land Authority according to the Land Authority

is to develop policies on continuous basis, undertake actions and implement programs in support of land

governance, including land administration and management. The LLA will be the principal agency for

the implementation of this project. The overall responsibility for implementing this ESMF therefore lies

with the LLA. The LLA will be required to mobilize the required resources for full implementation of the

ESMF and any other subsequent environmental and social action plan that may be developed in the

course of the project implementation. While a full-time safeguards specialist may not be required given

the low level of potential impacts, the LLA through its project implementation unit will be required to

hire short-term consultant for safeguards support on an as-needed basis. In support of the ESMF

implementation, the LLA will undertake a social assessment of the project during the baseline study,

prior to undertaking activities related to Component 2, which may have the potential to generate


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unspecified social risks and impacts which are not understood at this stage of the project. The LLA may

be required to report to the EPA on a quarterly basis or as may be required by the EPA on

implementation status of the ESMF and other action plans that may be developed during the course of

project implementation.

The Environmental Protection Agency of Liberia

The EPA is responsible for monitoring, coordinating, and supervising the sustainable management of

Liberia’s environment. It is mandated to ensure the conduct of EIA for projects and programs that are

likely to have significant adverse effects on the environment and people. The EPA is responsible for

issuing permit and conducting compliance audits to ensure that permit conditions are adhered to.

During the preparation of this ESMF, a brief was submitted to the EPA for review and approval as

required by the EIA guidelines. The project brief was reviewed and the decision to conduct further study

and develop an Environmental Review Report was reached. This ESMF has been prepared in fulfillment

of this decision as well as the World Bank OP 4.01 requirements for Category B for which specific

activities and sites are not defined at the project preparation stage. During project implementation, the

EPA has the statutory mandate to conduct compliance audit to ensure conditions of the issued

environmental permit are complied with by contractors as well as the LLA.

There are departments and units in other agencies and ministries that will be subsumed by the LLA. For

example, the Department of Lands, Surveys and Cartography (DLSC) under the former Ministry of Land,

Mines and Energy (Now Ministry of Mines and Energy) will be integrated in the LLA. Similarly, the Deeds

Registry which currently sits within the Center for National Documents and Records Agency (CNDRA),

and relevant functions from the Ministry of Internal Affairs (e.g. County Land Commissioners). Some of

these ministries and agencies might be important partners in overall project implementation but may

not have any specific roles with regards to safeguards implementation.

The World Bank

The Bank Task Team will be responsible for ensuring the timely commencement of the preparation of all

necessary plans as may be required. This will include the social assessment to be conducted during

baseline as well as plans that may be required during project implementation as a result of the social

assessment and environmental screening which will be undertaken prior to implementing activities that

are likely to have impacts on the environment and people. The task team will ensure that no contracts

for works that have a physical impact are signed or reconstruction, or rehabilitation of proposed

activities start without the required safeguards instruments in place.

6.0 Institutional Capacity for Safeguards Implementation and Training The LLA does not have the capacity for safeguards implementation as it has no experience in

implementing Bank-financed project. Basic safeguards training will be provided to the project

implementation staff to be able supervise and monitor ESMF implementation. The project may hire a

safeguards consultant to provide safeguards support on an as-needed basis.

7.0 SAFEGUARDS IMPLEMENTATION BUDGET

An estimated cost for implementing the ESMF including the ESMP has been developed. The safeguards

implementation budget also includes estimated cost for safeguards related studies such as social


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assessment that will be conducted during project implementation. The main components of the budget

comprise the following:

i. Training

ii. Review of the Environmental & Social Management Framework (ESMF)

iii. Implementation of Environmental and Social Mitigation Measures

iv. Environmental and Social Audits and Screening

v. Social Assessment

The estimated cost for implementing the framework ESMP and studies that may be conducted is US$ 42,

000. Breakdown per component is given in Table 2.

TABLE 2 SUMMARY BUDGET FOR IMPLEMENTATION OF ESMP

Item Estimated Cost (US$) 1. Training 5,000.00 2. Environmental Review and Permitting 2,000.00 3. Environmental and Social Mitigation Measures 10,000.00 4. Environmental and Social Audits and screening 15,000.00 5. Social Assessment 10,000.00

Total: 42,000

Training

Training is key to successful implementation of any environmental management program. A budget of

about US$5,000.00 may be required annually to implement the training programs for institutions and

persons required to implement the ESMP. This cost will cover transport, preparation of materials and

allowance for a certified environmental evaluator to conduct the training exercises.

Review and Permitting

Environmental Permit processing fee may be required in case the EPA will need to issue permit for this

project. Given that the project activities are low impact activities which did not require a full ESIA study,

this may not be required.

Environmental and Social Audits and Screening

A lump sum of US$15,000.00 is provided for implementing Environmental and Social audits and

screening annually. This amount also includes fees for hiring short-term consultant for safeguards

support when need be.

Social Assessment

The baseline survey and social assessment to be prepared by the Project in year one will provide

additional quantitative data on vulnerable groups and others. The Social Assessment is expected cost

US$ 10,000.

8.0 GRIEVANCE REDRESS MECHANISM

Grievance mechanisms provide a formal avenue for affected groups or stakeholders to engage with the

project implementers or owners on issues of concern or unaddressed impacts. Grievances are any


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complaints or suggestions about the way a project is being implemented. They may take the form of

specific complaints for damages/injury, concerns about routine project activities, or perceived incidents

or impacts. Identifying and responding to grievances supports the development of positive relationships

between projects and affected groups/communities, and other stakeholders.

The World Bank/IFC standards outline requirements for grievance mechanisms for some projects.

Grievance mechanisms should receive and facilitate resolution of the affected institutional or

communities’ concerns and grievances. The World Bank/IFC states the concerns should be addressed

promptly using an understandable and transparent process that is culturally appropriate and readily

acceptable to all segments of affected communities, at no cost and without retribution. Mechanisms

should be appropriate to the scale of impacts and risks presented by a project.

Grievances can be an indication of growing stakeholder concerns (real and perceived) and can escalate if

not identified and resolved. The management of grievances is therefore a vital component of stakeholder

management and an important aspect of risk management for a project.

Projects may have a range of potential adverse impacts to people and the environment in general,

identifying grievances and ensuring timely resolution is therefore very necessary. As such the ESMF has

developed a grievance management process to serve as a guide during project implementation.

The project proposes to make use of existing institutional structures under the LLA to facilitate the receipt and resolution of complaints during project implementation. This would be achieved through a 3-Tier arrangement.

Tier 1: Complaints will be recorded by dedicated officers at (i) the Local offices of the LLA and (ii) the LLA headquarter,

Tier 2: Unresolved grievances may be referred to the Office of the Executive Director of the LLA. A team will be constituted including legal and land experts for resolution

Tier 3: All unresolved grievances would be referred to the Board of Commissioners of the LLA for final determination. It is expected that an appropriate resolution would be made to the satisfaction of the complainant.

Where a complainant remains unsatisfied with the response or procedures of the project GRM recourse to the state courts becomes the final avenue.

9.0 STAKEHOLDER CONSULTATION

Public consultations were held in selected towns including Caldwell, Brewerville and Paynesville where the

local community members and their traditional leaders participated. Similar consultations took place in

Monrovia for targeted institutions such as the EPA, CSOs and Decentralized government ministries and

agencies of the LLA during the preparation of the ESMF. In addition, joint stakeholder consultations were

held in some places for the ESMF and on the Land Rights Bill.

TABLE 3 SUMMARY OF PUBLIC CONSULTATION



1 Caldwell 18

2 Brewerville 20

3 Paynesville 23

4 Taditional Leaders/ legal profession/CSOs

35


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5 EPA 12

7

10.0 DISCLOSURE

The disclosure is a requirement from the World Bank safeguard policies as well as from national

environmental assessment procedures, and therefore the report will be available to project affected

groups, local NGOs, and the public at large. The LLA will make copies of the ESMF available in selected

public places as required by law for information and comments as well as in the media. The ESMF will be

announced and published on an official Government website.


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11.0 Annexes Annex 1 Screening Checklist

S No ISSUES YES NO Comments

A. Zoning and Land Use Planning

1. Will the subproject affect land use zoning and planning or conflict

with prevalent land use patterns?

2. Will the subproject involve significant land disturbance or site

clearance?

3. Will the subproject land be subject to potential encroachment by

urban or industrial use or located in an area intended for urban or

industrial development?

B. Utilities and Facilities

4. Will the subproject require the setting up of ancillary production

facilities?

5. Will the subproject require significant levels of accommodation or

service amenities to support the workforce during construction

(e.g., contractor will need more than 20 workers)?

C Water and Soil Contamination

6. Will the subproject require large amounts of raw materials or

construction materials?

7. Will the subproject generate large amounts of residual wastes,

construction material waste or cause soil erosion?

8. Will the subproject result in potential soil or water contamination

(e.g., from oil, grease and fuel from equipment yards)?

9. Will the subproject lead to contamination of ground and surface

waters by herbicides for vegetation control and chemicals (e.g.,

calcium chloride) for dust control?

10. Will the subproject lead to an increase in suspended sediments in

streams affected by road cut erosion, decline in water quality and

increased sedimentation downstream?

11. Will the subproject involve the use of chemicals or solvents?

12. Will the subproject lead to the destruction of vegetation and soil in

the right-of-way, borrow pits, waste dumps, and equipment yards?

13. Will the subproject lead to the creation of stagnant water bodies in

borrow pits, quarries, etc., encouraging for mosquito breeding and

other disease vectors?

D. Noise and Air Pollution Hazardous Substances

14. Will the subproject increase the levels of harmful air emissions?

15. Will the subproject increase ambient noise levels?

16. Will the subproject involve the storage, handling or transport of

hazardous substances?

E. Fauna and Flora

18. Will the subproject involve the disturbance or modification of

existing drainage channels (rivers, canals) or surface water bodies

(wetlands, marshes)?

19. Will the subproject lead to the destruction or damage of terrestrial

or aquatic ecosystems or endangered species directly or by induced

development?

20. Will the subproject lead to the disruption/destruction of wildlife

through interruption of migratory routes, disturbance of wildlife

habitats, and noise-related problems?


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F. Destruction/Disruption of Land and Vegetation

21. Will the subproject lead to unplanned use of the infrastructure

being developed?

22. Will the subproject lead to long-term or semi-permanent

destruction of soils in cleared areas not suited for agriculture?

23. Will the subproject lead to the interruption of subsoil and overland

drainage patterns (in areas of cuts and fills)?

24. Will the subproject lead to landslides, slumps, slips and other mass

movements in road cuts?

25. Will the subproject lead to erosion of lands below the roadbed

receiving concentrated outflow carried by covered or open drains?

26. Will the subproject lead to long-term or semi-permanent

destruction of soils in cleared areas not suited for agriculture?

27. Will the subproject lead to health hazards and interference of plant

growth adjacent to roads by dust raised and blown by vehicles?

G. Cultural Property

28. Will the subproject have an impact on archaeological or historical

sites, including historic urban areas?

29. Will the subproject have an impact on religious monuments,

structures and/or cemeteries?

30. Have Chance Finds procedures been prepared for use in the

subproject?

H. Expropriation and Social Disturbance

31. Will the subproject involve land expropriation or demolition of

existing structures?

32. Will the subproject lead to induced settlements by workers and

others causing social and economic disruption?

33. Will the subproject lead to environmental and social disturbance by

construction camps?

S No ISSUES YES NO Comments

1. Is the subproject located in an area with designated natural

reserves?

2. Is the subproject located in an area with unique natural features?

3. Is the subproject located in an area with endangered or

conservation-worthy ecosystems, fauna or flora?

4. Is the subproject located in an area falling within 500 meters of

national forests, protected areas, wilderness areas, wetlands,

biodiversity, critical habitats, or sites of historical or cultural

importance?

5. Is the subproject located in an area which would create a barrier for


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the movement of conservation-worthy wildlife or livestock?

6.

Is the subproject located close to groundwater sources, surface

water bodies, water courses or wetlands?

7. Is the subproject located in an area with designated cultural

properties such as archaeological, historical and/or religious sites?

8. Is the subproject in an area with religious monuments, structures

and/or cemeteries?

9. Is the subproject in a polluted or contaminated area?

10. Is the subproject located in an area of high visual and landscape

quality?

11. Is the subproject located in an area susceptible to landslides or

erosion?

12. Is the subproject located in an area of seismic faults?

13. Is the subproject located in a densely populated area?

14. Is the subproject located on prime agricultural land?

15. Is the subproject located in an area of tourist importance?

16. Is the subproject located near a waste dump?

17. Does the subproject have access to potable water?

18. Is the subproject located far (1-2 kms) from accessible roads?

19. Is the subproject located in an area with a wastewater network?

20. Is the subproject located in the urban plan of the city?

21. Is the subproject located outside the land use plan?

Signed by Environment Specialist: Name: _______________________________

Title: _______________________________

Date: _______________________________

Signed by Project Manager: Name: _______________________________

Title: _______________________________

Date: _______________________________

Annex 2 Stakeholder Meeting in Caldwell

QUESTION ASKED RESPONSES/CONCERNS


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No.

1 Do you know the process of land

acquisition?

About 85% of respondents were not clear of the entire

process. Most relied on the surveyor to walk them through.

2 Do you usually participate in the

survey process?

Almost 80% said they do not physically participate,

because they rely on their chosen surveyor to participate.

3 How do you know if the metes

and bounds on your deed is

correct?

Almost all respondents accepted their documents to be

correct because they believe their surveyors. Most sellers

and buyers don’t follow the surveyors.

4 Are you ok with the time and cost

of the process?

About 60% of respondents agree that the process is too

long because of the bureaucracy involved; and cost was

high and uncertain.

5 How much influence, you think,

Gov. officials and other influential

personalities have on the

process?

About 20% of respondents agree that Government officials,

the courts and other Authorities use their influence or

financial strength to skew a survey result in their favour.

Participants at Stakeholder Meeting in Caldwell

Names Contact Position

Henry d. May son Sr. 0886529764 Elder

Reuben R. Johnson 0777211732 Elder

Clarissa Q. Robertson 0777248478 Elder

Fredrick Gibson 0776567238 Elder

Saykay Koffah 0776167527 0776167527

J. Washington Kpor 0886577674 Elder

Branford J Weah 0886138679 Youth Chairman

Anna Teah 0888307591 Elder

James Holcombe 0886669828 Elder

Joe Mulbah 0880984027 Elder

Zwannah Dukuly 0770164135 Elder

Richer M. Tucker 077712751 91 Elder

Tomah Sabah 07771671067 Elder

Rebecca M. Tamara - Bassa Vice Governor

James Sarpu 0777975518 Elder

J. Benedict Glaywor 0777959 568 Elder

Abraham L. Sonnie 0775 954418 Vai Governor

Joanna Minor 0886621328 Elder


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Photos of Participants at Stakeholders’ Meeting in Caldwell


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Annex 3 Stakeholder Meeting in Brewerville

No. QUESTION ASKED RESPONSES/CONCERNS

1 Do you know the process of

land acquisition?


process. Most relied on the surveyor to walk them

through.

2 Do you usually participate in

the survey process?




and bounds on your deed is

correct?




4 Are you ok with the time and

cost of the process?



high and uncertain.

5 How much influence, you

think, Gov. officials and other

influential personalities have

on the process?

About 10% of respondents agree that Government

officials, the courts and other Authorities use their

influence or financial strength to skew a survey result in

their favour.

Participants at Stakeholder Meeting in Brewerville

NAMES CONTACT POSITION

Henry Dukuly 0886997780 Elder

Momo Massaley 0880523071 Elder

E. Tonieh Williams 0886577958 Elder

Cyrus k. Domah 0886422483 Youth

Exodus C.P Gant 0880491822 Adult

Samuel Holder 0880278562 Youth

Varney S. Gant 0886762771 Elder

Robert S. Korfleh 0880703914 Youth

Francis Fayiah 0775125221 Youth

Prince Keibah 0776331071 Youth

Albert Nah 0886409377 Elder

Moses Sango 0886341424 Elder

Bill A. Brown 0886132743 Elder

Jerry W. Richards 0886812593 Asst. Mayor

Momo K. Kiazolu 0880122221 Elder

Francis C. Kemah 0888315779 Elder

Lasana C. Zoedua 0888301115 Elder

Emmanuel A. Williams 0886444314 Elder

Jamon Banks 0777412098 Elder

Momo K. Cassell 0776422508 Elder


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Photos of participants at Stakeholders’ Meeting in Brewerville


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Annex 4 Stakeholder Meeting in Paynesville

Stakeholder Meeting in the Township of Paynesville

Name Contact Position

Philip J. Beah 0886837151 Director Env. Health

Massa L. Addis 0886514286 Director/CSD

Alexander Gbarbea 0886774299 Social Worker

Lomenie Brown 0886389550 Inspector/PC

Yurmah Okai 0886453168 Elder

Lionel T. Weah 0886334173 Elder

Fatu B. G. Zinnah 0886644173 Elder

Simpkin S. Sneh 0886321133 Elder

Alousius Chieh 0886519560 Elder

Othello Moore 0777656676 Elder

James M. Kennedy 0886438188 Elder

Leatha M Dahn 0886535980 Elder

Tito T. Murray 0886872693 Elder

Robert H. B. Miller 0886897659 Elder

Prince G. Troh 0886453496 Youth

Manie Dolo 0886292077 Elder

Benjamin Barker 0777608811 Elder

Augustine B. Kpakolo 0886997044 Elder

Steven M. Mongen - Elder

Cynthia S. William 0777208045 Elder



land acquisition?



through.


the survey process?


because they rely on their chosen surveyor to

participate.

3 How do you know if the

metes and bounds on your

deed is correct?


correct because they believe their surveyors. Most

sellers and buyers don’t follow the surveyors.





high and uncertain.


think, Gov. officials and other

influential personalities have

on the process?



influence or financial strength to skew a survey result

in their favour.


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Shad Wolozolah - Elder

Jesse Blaise 0886781693 Elder

Tornue Dorboryan 088684212 Elder

Photos of Participant at Stakeholders’ Meeting in Paynesville


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Annex 5 Stakeholder Meeting with Civil Society Groups



land acquisition?



through.


the survey process?




and bounds on your deed are

correct?








high and uncertain.


think, Government officials

and other influential


process?




their favour.

Participants at Stakeholder Meeting with Civil Society Groups

Name Contact Position

Joseph B. Trinity 0880434789 MANIA-LIB

Adolphus Kawah 0886207962 CSO NETWORK/DWI

Tommy O. Goll 0886548906 MO-JL

Semsee Kiadii 0886604032 CSO

Photos of Stakeholders’ Meeting with Civil Society Group


34 | P a g e

Annex 6 Stakeholder Meeting with Environmental Protection Agency



land acquisition?



through.


the survey process?




and bounds on your deed are

correct?








high and uncertain.


think, Government officials

and other influential


process?




their favour.

Participants at Meeting with the Environmental Protection Agency

Name Contact Position Z. Elijah Whapoe 0886524657 Employee J. Adama Manobah 0886623817 Employee Jerry T Toe 0880662516 Employee Earl Neblett 0886546345 Employee Morris Gontor 0880854091 Employee Joseph Yeneken 0886988782 Employee Juluis B. Kawa 0886703467 Employee Edward G. Wingbah 0886576150 Employee McAlbert Donnie 0886960274 Employee Abayaomi Grant 0886531903 Employee Scholastica Doe 0886515567 Employee Varney Conneh 0886531029 Employee

Photos of Participants at Stakeholders’ Meeting with Environmental Protection Agency (EPA)

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